- 2 -
adjustments in the notice of deficiency overstated income that
petitioner received from Crawford & Co. by $2,236. There is no
disagreement regarding the remaining items which form the basis
for respondent's deficiency determination, and petitioner does
not argue that he is entitled to any deductions, credits, or
other allowances in addition to those used by respondent.
The only issue raised by petitioner at trial and in his
posttrial brief is his contention that the notice of deficiency
was improper because it was not supported by a properly signed
assessment. Thus, petitioner in his brief makes the following
argument:
Before any liability of any type can be created there
must be an assessment. That assessment must be
certified as a true and correct assessment by an
assessment officer. The Petitioner questions how a
NOTICE OF DEFICIENCY can state that this is "legal
notice" when legal notice could only be legal if it was
supported by a properly signed assessment. What
officer, agent, employee or other person is authorized
to issue a NOTICE OF DEFICIENCY without an assessment
being signed and certified to by an Assessment Officer?
According to IR Code section 6065, the NOTICE OF
DEFICIENCY has been improperly signed. Where is the
attested signature? The Petitioner desires to have the
Assessment Officer or other individual who has
certified to the correctness of this assessment be
identified. If there is no assessment, then the
petitioner would like to know who the person is that
created and caused to be sent a bill for $20,785.00
The Petitioner would like to subpoena that person as a
witness. At the present time, that person remains
unidentified.
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011